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V3695-20 ·30 December 2020 ·consulta-vinculante Medium impact
Tax

Special spin-off regime cannot be applied if segregated assets do not constitute business lines

The taxpayer asks whether a non-proportional total spin-off of industrial warehouses can qualify for the special regime under the Corporate Income Tax Act. The DGT rules that it cannot, as the transferred assets do not constitute autonomous business lines.

In 6 key points

How it affects those involved

Companies attempting to restructure by spinning off assets that do not function as independent business units will not benefit from the tax advantages of the special spin-off regime.

Lifecycle

2020-12-30PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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